Swarna v. Al-Awadi
Plaintiff Swarna Vishranthamma sued her former employers, Badar Al-Awadi and Halal Muhammad Al-Shaitan (Individual Defendants), and the State of Kuwait for slavery and slavery-like practices under the Alien Tort Claims Act (ATCA) and for labor law violations. The Individual Defendants claimed diplomatic immunity, and Kuwait claimed sovereign immunity. The court ruled that the Individual Defendants' alleged actions were private acts, not official diplomatic functions, thus denying them residual diplomatic immunity for both ATCA and labor law claims. Conversely, Kuwait was granted sovereign immunity from the labor law claims, as it was not the direct employer, and its financial support to the diplomat was deemed a sovereign act. Kuwait also retained immunity from the ATCA claims, as the diplomat's tortious acts were outside the scope of employment, and claims of ratification/aiding and abetting involved discretionary governmental functions. Consequently, the court granted the plaintiff's motion for a default judgment against the Individual Defendants but denied it against the State of Kuwait, dismissing all claims against Kuwait for lack of subject matter jurisdiction.